'Are you setting a proper tone and example on compliance and doing the right thing? Are you setting the right tone and doing the right things to develop your analysts?' Herr said of the new program, called 'Rewarding What Matters.' Employees can earn the bonus by, for example, raising issues with compliance, suggesting policy changes and serving on charitable boards.

The new policy is the latest step in a series of management and organizational changes that were announced by Cohen’s firm, after SAC stopped handling client money this year and reached a $1.8 billion settlement with the U.S.